The Better Money Company (“TBMC,” “we,” “us” or “our”) is a stablecoin clearinghouse technology platform that provides stablecoin swapping, clearing facilitation, and related services. This Privacy Policy describes how TBMC processes personal information that we collect through our digital and online properties or services that link to this Privacy Policy (including as applicable, our website, web application, application programming interfaces (APIs), member platform, electronic communications, and social media pages) as well as our marketing activities and other activities described in this Privacy Policy (collectively, the “Service”).
Our websites, products and services are designed for enterprise customers and their representatives. We do not offer products or services for use by individuals for their personal, family or household purposes. Accordingly, we treat all personal information we collect as pertaining to individuals in their capacities as representatives of the relevant enterprise and not their individual capacities.
This Privacy Policy does not apply to personal information that we process on behalf of our enterprise customers while providing services to them. Our use of information that we process on behalf of our enterprise customers is governed by our agreements with such customers. If you have questions regarding your personal information that we process on behalf of our enterprise customers, please direct your concerns to the enterprise customer with which you have a relationship.
This Privacy Policy does not apply to our job applicants, employees, independent contractors or other personnel.
Table of Contents
- Personal information we collect
- Tracking Technologies
- How we use your personal information
- How we share your personal information
- Your choices
- Advertising Choices
- Other sites and services
- Security
- International data transfers
- Children and Teens
- Changes to this Privacy Policy
- How to contact us
Personal information we collect
Information you provide to us. Personal information you may provide to us includes:
- Contact data, such as your first and last name, alias, signature, salutation, email address, employer information, billing and mailing addresses, and phone number.
- Demographic data, such as your city, state, country of residence, and postal code.
- Account data, such as account name, the username and password that you may set to establish an account on the Service, date of birth, preferences, and any other information that you add to your account profile.
- Transactional data, such as information relating to or needed to complete a transaction, including transaction amount, asset type, digital wallet address, transaction memos and timestamps, chain identifiers, recipient information (including name and address), and sender information (including name and address).
- Communications data based on our exchanges with you, including when you contact us through the Service, communicate with us via email, phone, chat features, social media, or otherwise.
- Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.
- User-generated content data, such as your comments, reviews, questions, works of authorship, and other content or information that you generate, transmit, or otherwise make available on the Service, including associated metadata. Metadata includes information on how, when, where and by whom a piece of content was collected and how that content has been formatted or edited. Metadata also includes information that users can add or can have added to their content, such as keywords, geographical or location information, and other similar data.
- Call/video recordings, such as recordings of support calls.
- Sensitive personal information, including Social Security numbers, government-issued identification documents, citizenship, financial account numbers and tax identification numbers.
- Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.
Data about others. We may offer features that allow for you to provide or otherwise make available to us information about others (for example, beneficial owners). Please do not provide others’ personal information unless you have their permission to do so.
Third-party sources. We may combine personal information we receive from you with personal information of the kinds identified above that we obtain from other sources, such as:
- Public sources, such as credit bureaus, government agencies, public records, publicly accessible social media profiles, and other publicly available sources.
- Identity and compliance providers, such as identity verification platforms and sanctions and watchlist screening services.
- Data providers, such as information services, data licensors/brokers, AI data enrichment providers, lead generators and cooperative databases.
- Service providers that provide services on our behalf or help us operate the Service or our business.
- Partners, such as joint marketing partners and event co-sponsors.
- Ad networks
- Data analytics providers
- Social media platforms
Automatic data collection. We, our service providers, and our advertising partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Service, our communications and other online services, such as:
- Device data, such as your computer or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, and radio/network information (e.g., Wi-Fi, LTE, 3G).
- Location data, which may be approximate (for example, as inferred from network data, IP address, or device settings).
- Communication interaction data such as your interactions with our email, text, chat or other communications (e.g., whether you open and/or forward emails) – we may do this through use of pixel tags (which are also known as clear GIFs), which may be embedded invisibly in our emails enabling us to detect if you have opened or forwarded a message.
- Online activity data, such as pages or screens you viewed, search history, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our emails or clicked links within them.
Tracking technologies. Some of the automatic collection described above is facilitated by the following technologies:
- Cookies, which are small text files that websites store on user devices and that allow web servers to record users’ web browsing activities and remember their submissions, preferences, credentials, and login status as they navigate a site. Cookies used on our sites include both “session cookies” that are deleted when a web browser session ends, “persistent cookies” that remain longer, “first party” cookies that we place and “third party” cookies that our service providers and other third parties place.
- Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed, clicked or forwarded.
How we use your personal information
We may use your personal information for the following purposes or as otherwise described at the time of collection:
Service delivery and operations. We may use your personal information to:
- provide and operate the Service and our business;
- process your requests, orders and transactions;
- enable security features of the Service;
- personalize the service, including remembering your devices, selections and preferences as you navigate the Service;
- establish and maintain your account on the Service;
- communicate with you about the Service, including by sending Service-related announcements, updates, security alerts, and support and administrative messages;
- understand your needs and interests, and personalize your experience with the Service and our communications;
- provide support for the Service, and respond to your requests, questions and feedback;
- conduct know-your-business (“KYB”) and know-your-customer (“KYC”) analyses;
- collect and share testimonials; and
- fraud prevention and security.
Research and development. We may use your personal information for research and development purposes, including to develop, analyze and improve our products and services. As part of these activities, we may create aggregated, de-identified or other anonymous data from personal information. We may use this anonymous or de-identified data and share it with third parties for any lawful business purposes. We do not attempt to reidentify deidentified information derived from personal information, except as permitted by applicable law including, for example, for the purpose of testing whether our deidentification processes comply with applicable law.
Marketing and advertising. We and our third-party advertising partners may collect and use your personal information for marketing and advertising purposes:
- Direct marketing. We may send you direct marketing communications and may personalize these messages based on your needs and interests. You may opt-out of our marketing communications as described in the Opt-out of communications section.
- Events, promotions and contests. We may use your personal information to administer promotions and contests, communicate with you about events in which you participate, or contact or market to you after collecting your personal information at an event.
Compliance and protection. We may use your personal information to:
- comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas, court orders, investigations or requests from government authorities;
- fulfil our anti-money laundering and know-your-business and know-your-customer (“KYB/KYC”) obligations, screen against sanctions lists, file suspicious activity and other regulatory reports, and perform ongoing compliance checks and due diligence;
- protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);
- audit our internal processes for compliance with legal and contractual requirements or our internal policies;
- enforce the terms and conditions that govern the Service; and
- prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including unauthorized or fraudulent transactions, cyberattacks and identity theft.
With your consent. In some cases, we may specifically ask for your consent to collect, use, or share your personal information for further purposes, if those purposes are not compatible with the initial purpose for which that personal information was collected.
Cookies and similar technologies. In addition to the other uses included in this section, we may use the tracking technologies described above for the following purposes:
- Technical operation. To allow the technical operation of the Service, such as remembering selections as you navigate the site and remembering whether you are logged in.
- Functionality. To enhance the performance and functionality of our services.
- Analytics. To help us understand user activity on the Service, including the volume and demographics of users, which pages are most and least visited and how users move around the Service or interact with our emails. For example, we use Google Analytics for this purpose. You can learn more about Google Analytics and how to prevent the use of Google Analytics relating to your use of our sites here: https://tools.google.com/dlpage/gaoptout.
Data sharing in the context of corporate transactions, we may share certain personal information in the context of actual or prospective corporate transactions – for more information, see How we share your personal information, below.
How we share your personal information
We may share your personal information with the following parties and as otherwise described in this Privacy Policy, in other applicable notices, or at the time of collection.
Affiliates. In some cases, our corporate parent, subsidiaries, and affiliates might have access to personal information.
Custodians. BitGo Bank & Trust, National Association (“BitGo”) serves as our custodian and settlement provider and we share personal information with BitGo to perform custodial, settlement, compliance and other services. We do not control how BitGo may use your personal information.
Service providers. Third parties that provide services on our behalf or help us operate the Service or our business (such as hosting, internet service providers, information technology, customer support, email delivery, marketing, consumer research and website/data analytics).
Compliance providers. We share your personal information with certain compliance providers for purposes such as identity verification, sanctions screening, and KYB/KYC compliance. We do not control how these providers may use your personal information. For example, we use Persona Identifies, Inc. (“Persona”) for certain of these compliance functions. Persona’s privacy policy, available at https://withpersona.com/legal/privacy-policy, governs its processing of your personal information.
Advertising partners / ad networks. Third-party advertising companies for the interest-based advertising purposes described above.
Social networks. We use their ad services to display ads to our customers, or other people like them, on social media.
Third parties designated by you. We may share your personal information with third parties where you have instructed us or provided your consent to do so.
Sponsor Partners. Third parties with whom we partner, including parties with whom we co-sponsor events or promotions, with whom we jointly offer products or services, or whose products or services may be of interest to you.
Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.
Authorities and others. Law enforcement, government authorities, and private parties in litigation, as we believe in good faith to be necessary or appropriate for the Compliance and protection purposes described above.
Corporate transactions. We may disclose personal information in the context of actual or prospective business transactions (e.g., investments in or financings of TBMC, public stock offerings, the sale, transfer or merger of all or part of our business, assets or shares, liquidation or reorganization). For example, we may need to share certain personal information with prospective counterparties and their advisers. We may disclose your personal information to an acquirer, successor, or assignee of TBMC or a portion of our business assets as part of any merger, acquisition, sale of assets, or similar transaction, and/or in the event of an insolvency, bankruptcy, or receivership in which personal information is transferred to one or more third parties as one of our business assets.
Other users and the public. Due to the nature of blockchain technologies, any data posted to or otherwise interacting with public blockchains will be visible to other users of the Service and the public. Information about your interactions and/or transactions will be provided to the applicable blockchain network and may be accessible to third parties due to the blockchain protocol’s nature. This information can be seen, collected and used by others, including being cached, copied, screen captured or stored elsewhere by others (e.g., search engines), and we are not responsible for any such use of this information. It may be possible for someone to identify you through your pseudonymous, public wallet address using external information sources, and any transaction you enter or otherwise interact with the relevant blockchain could possibly be used to identify you or information about you.
Your choices
In this section, we describe the choices available to you.
Access or update your information. You may have the right to access and update personal information we hold about you.
Opt-out of communications. You may opt-out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us. It may take time for your opt-out to be effective. Please note that if you choose to opt-out of marketing-related emails, you may continue to receive service-related and other non-marketing emails.
Cookies. Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. Please note that if you set your browser to disable cookies, the Service may not work properly. For more information about cookies, including how to see what cookies have been set on your browser and how to manage and delete them, visit http://www.allaboutcookies.org .
Blocking images/clear gifs: Most browsers and devices allow you to configure your device to prevent images from loading, so the business hosting the image will not detect that you have viewed a page. To do this, follow the instructions in your particular browser or device settings.
Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
Declining to provide information. We need to collect personal information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.
Retention Period for Personal Information. We generally retain personal information to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes. To determine the appropriate retention period for personal information, including Sensitive Personal Information, we may consider factors such as the length of time we have an ongoing relationship with you and provide services to you; the amount, nature, and sensitivity of the personal information; the potential risk of harm from unauthorized use or disclosure of your personal information; the purposes for which we process your personal information and whether we can achieve those purposes through other means; whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); whether retention is advisable in light of our legal position, such as in regard to applicable statutes of limitations, litigation or regulatory investigations; and applicable legal requirements. For example, we will retain your personal information for as long as you have an account with us or keep using our services, and the length of time thereafter during which we may have a legitimate need to reference your personal information to address issues that may arise. When we no longer require the personal information we have collected about you, we may either delete it or de-identify it.
Other sites and services
The Service may contain links to websites, mobile applications, and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.
Security
We employ technical, organizational and physical safeguards that are designed to protect the personal information we collect. However, security risk is inherent in all Internet and information technologies, and we cannot guarantee the security of your personal information.
International data transfer
We are headquartered in the United States and may use service providers that operate in other countries. Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country.
Children and Teens
The Service is not intended for use by anyone under 18 years of age. If you are a parent or guardian of a minor from whom you believe we have collected personal information, or if information was provided on your behalf when you were under 18, please contact us. If we learn that we have collected personal information through the Service from a child without the consent of the child’s parent or guardian as required by law, we will comply with applicable legal requirements to delete the information., we will comply with applicable legal requirements to delete the information.
Changes to this Privacy Policy
The "LAST UPDATED" legend at the top of this Privacy Policy indicates when this Privacy Policy was last revised. We reserve the right to modify this Privacy Policy at any time. We will notify you by updating the “Last Updated” date. Depending on the kind of change we make, we may also notify you directly or ask for your consent to the change. Any modifications to this Privacy Policy will be effective upon our posting the modified version or as otherwise indicated at the time of posting.
How to contact us
Email: privacy@bettermoney.com